Meadows Collier Partners Submit Comments on Proposed Updates to the IRS's Voluntary Disclosure Practice

Firm partners Jeffrey M. Glassman and Matthew L. Roberts, through their respective leadership positions in the State Bar of Texas Tax Section, recently submitted comments to the Internal Revenue Service regarding proposed updates to the IRS’s Voluntary Disclosure Practice (VDP).

On March 20, 2026, the Tax Section submitted its comments in response to the IRS’s request for feedback on proposed changes to the VDP framework. The proposed updates address, among other things, the program’s penalty structure and a new requirement that taxpayers fully pay tax, interest, and penalties within a limited timeframe to participate.

The Tax Section’s comments commend the IRS’s efforts to provide greater clarity and consistency in the VDP but recommend modifications to promote greater taxpayer participation. In particular, the comments suggest (i) adopting a more balanced approach to willful FBAR penalties and (ii) allowing more flexible payment options, including installment arrangements or other collection alternatives for taxpayers unable to fully pay within the proposed timeframe.

The Tax Section’s full comments can be found here.

If you have any questions about the comments submitted to the IRS on the proposed updates to the Voluntary Disclosure Practice on behalf of the State Bar of Texas Tax Section, or any civil or criminal tax issue, you can contact Mr. Glassman at jglassman@meadowscollier.com or Mr. Roberts at mroberts@meadowscollier.com.